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Perhaps I should have said grounds.

Bristol council appeal website stated that only one representation is allowed per PCN, when I tried to post my representations and then promptly deleted all but one of my grounds so I assumed that their understanding is that representations and grounds are one and the same.

I can see nothing in the legislation that forbids multiple representations only that representations must be submitted before 28 days;
 
(2) The charging authority may disregard any such representations which it receives after the end of the period of 28 days beginning with the date on which the penalty charge notice was served.

The following allows multiple representations

11.—(1) Where a charging authority serves a notice of rejection under regulation 10(1) in relation to representations made under regulation 8, the person making those representations may appeal to an adjudicator against the charging authority’s decision—

(5) On an appeal under this regulation the adjudicator must consider the representations in question and any additional representations which are made by the appellant together with any representations made to the adjudicator by the charging authority.

Hi
Thanks for the info/input.
My feelings are that the two points are linked because of the format of the Bristol PCN.
I will raise representations on both points, as the legislation is quite clear that the information "must" be included on the PCN.
The Dart Charge PCN is different in that it required payment of the penalty charge and daily charge combined, with no option for anything else, Bristol's is slightly different as it is unclear what payment is required and when that payment is required, although in the section "what are my options now", it does only give options that include the CAZ charge.
Julian

Hi

The legislation is the legislation you posted in the link
The pictures are now correct
julian